Ex parte Rowe

In Ex parte Rowe, 853 S.W.2d 581 (Tex. Crim. App. 1993), the defendant sought release from pretrial detention based upon Tex. Code Crim. Proc. article 17.151 because the State failed to indict him within the ninety-day period that followed his incarceration. Id. at 581-82. The court of criminal appeals concluded that in such a situation, article 17.151 requires a trial court to reduce a defendant's bail to an amount the record reflects that he or she can afford, or to release a defendant on personal bond when the record reflects that he or she cannot make any bond. Id. at 582 & n.1; see Tex. Code Crim. Proc. Ann. art. 17.151.